I have looked carefully at the UKCPS notice, the signage, and the status of the location, and I want to explain why the claim they are making is fundamentally flawed.
The road (Princes Square) where this was issued is part of the railway estate owned by Network Rail. At the time of the alleged event, land forming part of the railway estate was subject to statutory control through railway byelaws and was therefore not “relevant land” for the purposes of the Protection of Freedoms Act 2012. Because of that, UKCPS could not rely on PoFA to transfer liability from the unknown driver to the known registered keeper, regardless of the fact that their Notice to Keeper is headed “Postal – PoFA”. Keeper liability simply did not arise on railway land at the time of this incident, and any suggestion otherwise is misleading.
There has since been a legislative change, taking effect from 26 December 2025, which alters the definition of relevant land so that certain railway land may fall within PoFA going forward. However, that change is not retrospective. The applicable law is the law in force on the date of the alleged event. As this incident predates 26 December 2025, the change does not apply here and cannot be relied upon by UKCPS to create keeper liability after the fact.
The signage at the location is also contradictory and incapable of creating clear contractual terms. There is no PPSCoP- or IPC Code of Practice-compliant entrance sign to the station estate or to Princes Square itself. The only identifiable compliant entrance sign is positioned as drivers turn off Princes Square into the station forecourt and is specific to that forecourt area alone, not to the wider station estate or Princes Square roadway. That sign states “Private Land – Pick up & drop off only” and directs drivers to see signage within the pick-up/drop-off area for further terms. It therefore expressly permits stopping for the purpose of picking up or dropping off passengers, which necessarily involves stopping, even if only briefly. This permission cannot be reconciled with the separate repeater signs along Princes Square stating “No Stopping – £100 charge”, which purport to impose an absolute prohibition. Taken together, the signage is fragmented and internally inconsistent, and does not communicate any clear or coherent set of contractual terms to a driver.
Separately and in any event, a “No Stopping” sign is inherently prohibitive in nature. It does not make an offer capable of acceptance. A contract requires an offer and acceptance, and a sign that simply bans an activity does not offer permission to carry it out on terms. Where stopping is forbidden outright, there is nothing a driver can accept and no contractual licence being granted. At most, such signage could give rise to an allegation of trespass, which is a matter solely for the landholder and does not entitle a private parking company to impose a fixed contractual charge.
There is also a basic defect in the Notice to Keeper itself. It does not specify any period of parking. It provides only a single “time of issue”. A single timestamp is not a period. Despite this, the notice claims that the charge relates to “the period of parking specified above”, when no such period exists. That alone defeats any attempt to rely on PoFA, even on land where PoFA might otherwise apply.
The positioning of the signage further undermines their case. The alleged “No Stopping” sign is placed as drivers leave a public highway roundabout and enter Princes Square, and it runs parallel to the direction of travel. That placement does not give a driver a fair opportunity to read, understand, and consider terms before any alleged breach. Terms cannot be accepted if they are not reasonably communicated in advance.
It is also important to be clear about what actually happened. Stopping for a few seconds to check where you are or to look at directions is not the same as waiting or parking. Double yellow lines prohibit waiting, not stopping. The Highway Code makes a clear distinction between the two. Waiting means remaining in place for longer than is needed for the normal flow of traffic. A brief stop to orient yourself, check a sign, or confirm a turning is part of normal and safe driving and is not treated as waiting.
Even where there are double kerb blips, the restriction is only on loading and unloading. It does not create a no-stopping restriction. A genuine no-stopping restriction requires a clearway, a red route, or a specific no-stopping order backed by a Traffic Regulation Order. Without that, the law does not prohibit a momentary stop to check directions.
Private parking companies often try to pretend that any pause equals prohibited stopping, but that is not how road markings work and not how the Highway Code defines these restrictions. A momentary stop to check your location is simply not the kind of behaviour these restrictions are designed to regulate.
The overall position is that this was railway estate land where PoFA did not apply at the relevant time, the entrance signage expressly permits stopping for pick-up and drop-off, the signage relied upon by UKCPS is contradictory and prohibitive and incapable of forming a contract, the Notice to Keeper does not specify a period of parking, and the alleged conduct amounts to nothing more than a brief, lawful stop that forms part of normal driving. You should deal with this strictly as the registered keeper and you should not identify the driver.
So, the advice about the initial appeal still stands. We can make a clearer argument in the secondary appeal to the IAS, although that is not "independent" and is also not likely to be successful for the simple fact that you are now in the middle of a scam. That does not mean we don't try but, realistically, this would be easily defeated if they try to progress it to litigation in the county court as a small claim. There is no way they would let this progress to a hearing as they know they would be spanked.
Their MO is to hope that you are low-hanging fruit on the gullible tree and can be intimidated into paying out of ignorance and fear. That is the truth behind how these bottom-dwelling firms operate. Submit the appeal and come back when they reject with their reasoning.
